"I just don't think that's coincidental," said Hawkins, a legislative liaison for the state police. "People are going to use homelessness as some sort of guise."

But appeals court judges said it was impossible for the homeless to comply with the law that requires sex criminals to report their residence because they don't have one. They urged lawmakers to close the loophole.

In 2009, 5,118 people at some point experienced homelessness in the Grand Rapids and Kent County area, according to the Homeless Management Information System. Police aren't sure how many of Michigan's 260 sex offenders who list themselves as homeless are using the law to avoid registering, but they say the practice isn't unheard of.

Grand Rapids Police Officer John Wetzel said his department recently issued an arrest warrant for a sex offender who said he was homeless but was instead living at a home in Benton Harbor. Of the city's 750 registered sex offenders, eight listed themselves as homeless.

He says such violations could grow unless state lawmakers pass legislation that would require homeless sex criminals to register. Before the appeals court ruling, they were required to list their personal information on the state's sex offender registry website.

"The longer this is delayed," Wetzel said, "the longer people have to make up stories so they don't have to comply."

A group of Michigan lawmakers has introduced legislation that would require homeless sex offenders to list the location where they habitually sleep and to tell law enforcement officials within 10 days when that location changes by more than a half-mile.

But the legislation could face opposition from homeless advocates who say the law is overly burdensome and doesn't account for the transient lifestyle many homeless people lead.

State Sen. Bill Hardiman, who sponsored the legislation, said his support boils down to this: fairness.

"Even though homeless sex offenders lack a residence, it is still important for families living in the surrounding area to know they are close by," Hardiman, R-Kentwood, said in a statement.

The legislation has been approved in the Republican-controlled state Senate and awaits action in the Democratic-led state House of Representatives.

John Shea, an Ann Arbor criminal defense attorney whose list of clients has included homeless sex offenders, said the homeless community isn't against registration.

"If you require them to register every time they change a park bench, you're setting them up to fail," he said. "You're going to create more problems than you're solving."

Shea doesn't doubt there are sex offenders who have cast themselves as homeless to avoid registering, although he is not sure how common the practice has become.

"I don't think there's droves of people out there doing that," he said. "Anytime you show people there's a loophole, you'll find people who try to take advantage of it."

Other police agencies in West Michigan also are looking for guidance on how to handle homeless sex offenders.

"I hope that when the lawmakers finally get this enacted and put into law that the law will be clear to not only those who it will affect, but also law enforcement, so they have clear direction," said Lt. Mike Brookhouse of the Ottawa County Sheriff's Department.